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May 15, 2026

Ministerial Decision No. 55 of 2025 establishes Kuwait's Domestic Minimum Top-up Tax (DMTT) framework under Decree-Law No. 157 of 2024. Article 19 specifies a mandatory adjustment for calculating the GloBE Income or Loss of a Constituent Entity. It stipulates that the entity's financial accounting net income or loss (FANIL) must be adjusted for accrued pension expenses. This adjustment equals the difference between the total pension contributions paid to a Pension Fund and the pension expense amount recognised in the financial accounts for that same Tax Period.

CHAPTER 3 - GLOBE INCOME OR LOSS

Article 19 - Accrued Pension Expenses

To determine the GloBE Income or Loss, the FANIL is adjusted for each CE by the amount of accrued Pension Expense, and the required adjustment is the difference between:

Pension contributions paid to the Pension Fund during the Tax Period.
The amount recognized as an expense with respect to that Pension Fund in the computation of FANIL during the Tax Period.